Transfer pricing comparability for logistic support services...

Transfer pricing comparability for logistic support services turned on functional similarity: Cyber Media Research Ltd. was accepted as a comparable because it provided market research and management consultancy support services, subject to the related party transaction filter, while Apitco Ltd. was excluded as a government-owned company and BVG India Ltd. was excluded for functional dissimilarity arising from facility management, housekeeping and waste-management activities without a separate low-end services segment. The Tribunal upheld these comparability findings and rejected the Revenue's challenge. The assessee's claim that reversal of forex loss had been taxed twice was not finally decided on the existing record and was remanded to the jurisdictional Assessing Officer for fresh factual verification after hearing the assessee.

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